first he named a price of $30,000. Finally he came down to $20,000. Of course we didn't want to pay anything, but we knew that trouble would result, so we agreed to $20,000. I wouldn't give it to him all at once and he demanded currency. I gave him $5,000 a few days after our agreement; when the building was half completed, I gave him another $5,000, and when the building was completed about last December, I paid him the last $10,000. We did not have a bit of trouble on the building."

The whole case furnishes another striking example of the evils of the closed shop system. The business agent, with complete control of the workers and the power to call strikes at will, is quick to see the money making possibilities of his position. Boyle became too confident, ceased to take any precautions toward concealing his operations, and exposure followed. His scheme, however, is in force to a greater or less extent wherever the closed shop union has any measure of control. It is the natural product of the closed shop system.

Railroads to be Commended on Patriotic Stand

On March 19th, prior to the handing down of the decision on the Adamson Law, by the U. S. Supreme Court, the Railway Managers' Committee, in the following notification to President Wilson, granted all demands made by their employees:

"In the national crisis precipitated by events of which we heard this afternoon, the national conference committee of railroads joins with you in the conviction that neither at home nor abroad should there be fear or hope that the efficient operation of the railroads of the country will be hampered or impaired.

"Therefore, you are authorized to assure the nation there will be no strike, and as a basis for such assurance we hereby authorize the committee of the Council of National Defense to grant to the employees who are about to strike whatever adjustment your committee deems necessary to guarantee the uninterrupted and efficient operation of the railroads as an indispensable arm of national defense."

UNION BOYCOTTS*

Unions Lose in Two Cases for Interfering with Right to Sell Goods

Loewe v. Savings Bank of Danbury

The Supreme Court of the United States has rendered a favorable decision in the above entitled case, which clears the way for further progress in the collection of the judgment in the Danbury Hatters' case. It will be recalled that when the savings bank accounts of the individual members were attached, the Hatters' Union paid the defendants the face value of these accounts and took an assignment of them, subject to the rights of Loewe & Co. as attaching creditor. As the suit continued over ten years, the accumulated dividends declared by the respective savings banks on the various attached deposits reached the sum of approximately $20,000, which was claimed by the Hatters' Union on the ground that the dividends, not having been in existence when the attachments were levied, were not held by attachment and belonged to the Hatters' Union as the purchaser and owner of the respective bank accounts. On appeal of Loewe & Co., the Circuit Court of Appeals, reversing the decision of the District Court against Loewe & Co., declared that Mr. Loewe, as attaching creditor, was entitled to the accumulated dividends, and the Union thereupon appealed to the Supreme Court of the United States, which has finally held that this $20,000 belongs to Loewe & Co.

When the $20,000 involved is turned over to Mr. Loewe, as it will be after the mandate of the Supreme Court has been sent down, his total collections toward the payment of the judgment will slightly exceed $55,000, and steps will then promptly be taken to sell at public auction the one hundred and forty homes in Danbury, Bethel and Norwalk in connection with the pending foreclosure proceedings.

*Bulletin of American Anti-Boycott Association.

Justin Seubert, Inc., v. Reiff

This was an action for injunction and $100,000 damages against the Local Cigarmakers' Union in Syracuse, the Central Trades & Labor Assembly of Syracuse, the International Cigarmakers' Union, certain other local unions and some individuals who were union officers or pickets.

A preliminary injunction was secured on February 16th, 1916, which resulted in the removal of the pickets and the discontinuance of all hostile acts, as far as we are informed, and the case was tried in May, 1916. On January 29th, 1917, Judge Andrews, who tried the case, and who has recently been elevated to the Court of Appeals of the State of New York, rendered his decision. He holds that a peaceful strike to compel a manufacturer to use the union label, and peaceful picketing in furtherance of such a strike, are not illegal and that the rules surrounding the use of the cigarmakers' label and the arrangements between the Cigarmakers' Union and the various manufacturers in connection therewith are not illegal. Following what has been the accepted law in New York State in cases of this character, he holds that a peaceful appeal to the public not to buy the goods of some manufacturer with whom the union has a quarrel, is not in violation of law. At this point, he states, the rights of the defendants in their effort to control the action of a manufacturer cease, and steps beyond this limit are unlawful.

"Efforts were made to prevent customers of the plaintiff from selling its product. This was done by picketing in one instance-by the distribution of cards calling such customers unfair by disciplining union men who dealt with them or were employed by them and sold the plaintiff's goods for them, and by threatening those customers with loss of trade. It is said these acts violated both the State and the United States statutes. * * * I have no doubt that the union owning the label, or anyone else, may recommend the purchase of goods on which it is placed in preference to others. The trouble arises if a further step is taken and dealers are threatened with loss

or injury in case they sell either unlabeled goods generally or some goods made by a certain manufacturer. That may be an injury to commerce-an effort to create a monopoly. * * * The courts must be governed in their action by common sense and considerations of public policy. An act may, when committed in concert with others, under certain circumstances, cause such injury to the public and may be so useless or so unfair that these conditions will be decisive. Such an act is a secondary boycott. It must be held to be an unlawful interference with trade and commerce. Those who agree to bring it about are engaged in a conspiracy. One injured by it may come to a court of equity for relief.• *

* *

"Although the object is legal, a combination to accomplish it by threatening, expressly or by implication, those who buy the employer's goods, with loss of trade or a combination to injure their trade, is unlawful. All who join in such threats or in the acts of injury are conspirators and are liable for the damages caused by them. Not only the dealers directly affected but the original employer may recover such damages as the evidence shows they have severally suffered."

Judge Andrews then dismissed the case as to those defendants who he felt were not shown to have participated in the secondary boycott, but held the case as to the principal defendants against whom he awarded an injunction and damages to be assessed. The decision is of importance in view of the unsettled state of New York law on the subject of boycotting.

MICHIGAN ANTI-INJUNCTION LEGISLATION Extract from an Address of Mr. J. G. Hoffman, Secretary, Michigan Manufacturers Association before the Annual Convention of State Association of Builders' Exchanges

Mr. Chairman and Gentlemen: Mr. Bowen asked me to talk to you this morning about "Proposed Laws Inimical to Building Interests," and I decided to talk on the proposals of the Michigan Federation of Labor to change our Constitution so that injunctions cannot issue in labor disputes.

Petition to Amend the Constitution of the State of Michigan

The proposed amendment is to stand as new sections to the Constitution, and to read as follows:

1. No restraining order or injunction shall be granted by any court of the state, or any judge or judges thereof, in any case involving or growing out of a dispute concerning employment or the terms or conditions thereof.

2. It shall not be unlawful for any person to make, enter into or carry on any arrangement, agreement or combination made with the view of lessening or changing the hours of labor, or increasing wages, or altering the scale thereof, or altering or bettering the conditions of working men or working women, or prescribing the terms or conditions upon which they shall work, or carrying on collective bargaining concerning employment or the terms or conditions thereof, or doing, in pursuance thereof, any act which would be lawful if done by a single individual in the absence of such arrangement, agreement or combination; to terminate any relation of employment; to recommend, advise or persuade others so to do; to cease to perform any work or labor; to recommend, advise or persuade others so to do; to attend any place for the purpose of obtaining information from or communicating information to any person relative to any dispute concerning employment or the terms or conditions thereof; to persuade any person to work or abstain from working; to attend any place for the purpose of